March 2021—When the federal Occupational Safety and Health Administration (OSHA) passed its final crane rule (1926 Subpart CC) in November 2018, the crane industry had long anticipated its requirement for operators to be certified. Those in other related industries such as the pile driving industry, however, may not have realized that they were also impacted. Not only does the rule apply to those who use pile driving attachments on cranes, but it also applies to dedicated pile drivers. In fact, the full rule applies to dedicated pile drivers except for the requirements for anti two-blocking devices and load weighing and similar devices (the latter only on equipment manufactured after November 2011).
A key requirement of the new rule calls for employers to ensure that their operators are “qualified,” but there are three components to the qualification process: training, certification and evaluation. First, each operator-in-training must be provided with sufficient training, through a combination of formal and practical instruction, to ensure that the operator-in-training develops the skills, knowledge and ability to recognize and avert risk necessary to operate the equipment safely for assigned work.
Next, operators must be certified by a nationally accredited, third-party certification body to be sure that industry-recognized criteria for written testing materials, practical examinations, test administration, grading, facilities/equipment and personnel have been met. While “all stakeholders reiterated that operator certification is beneficial in establishing a minimum threshold of operator knowledge and familiarity with very basic crane operation,” OSHA states, “every employer with whom OSHA spoke stated that the employer’s role in ensuring the competency of crane operators should be allowed to continue.”
As a result, OSHA also requires that employers evaluate their operators to ensure they have the skills and knowledge necessary to operate the equipment they are assigned as well as the activities required. Operators must also demonstrate they have the ability to “recognize and avert” risk. This evaluation must be done by a qualified person and documented. The evaluation document, which must be made available at the worksite, must include the names both of the operator and the evaluator (who also has to sign it), the date the evaluation was conducted and the make, model and configuration of the equipment.
CCO Dedicated Pile Driver Operator Certification
Not to be lost in all of this, a key aspect of qualification is certification. The National Commission for the Certification of Crane Operators (NCCCO) provides the only nationally accredited third-party certification for dedicated pile driver operators. In anticipation of the then-pending OSHA rule, NCCCO and PDCA jointly developed the NCCCO dedicated pile driver operator certification and made it available in January 2017. Until then, no independent mechanism had existed for operators to demonstrate the knowledge, skills and abilities required of these specialized pieces of equipment.
When developing this new certification, NCCCO used a job analysis process to define the knowledge and skills needed for individuals to competently perform their duties. NCCCO Certification Team psychometricians worked with subject matter experts to identify duties and tasks that potential certificants perform on a regular basis. A representative sample of practitioners was then surveyed to identify which tasks, knowledge and skills are most important for a certified individual to know and be able to perform. Survey data was used to determine what knowledge and skills to test for on certification assessments, and how much weight is to be applied to each content area. The information compiled was then used to define the target content for CCO certification exams, both written and practical. This process ensured that the new certification is fair, valid, reliable and defensible.
To become CCO-certified for a five-year period, operators must meet eligibility requirements, pass a multiple-choice written examination and pass a practical examination that tests dedicated pile drivers’ real-world skills using these unique machines. The NCCCO website has detailed instructions for locating and applying for written and practical exams, but the basic process is as follows:
- Learn about the certification by reviewing the Dedicated Pile Driver Operator area of the NCCCO website and/or downloading the Dedicated Pile Driver Operator Candidate Handbook, which includes detailed exam contents.
- Prepare for your exams on your own or attend training. While some experienced operators may be able to pass the certification exams without formal training, training will benefit most and improve their likelihood of passing the exams on their first attempt. Because of its third-party status as an independent provider of certification, NCCCO is not able to endorse any particular training company or training program; however, in an effort to facilitate selection of an appropriate training vendor, NCCCO maintains a directory of training providers that have indicated they offer preparatory training for CCO certification exams. Some classes are scheduled at the trainer’s location; for larger groups, some trainers will provide training at a client’s location.
- Apply and schedule your written exam via either paper/pencil testing (PPT) or computer-based testing (CBT). Upcoming open PPT exam administrations are listed on the NCCCO website. CBT exams may be taken at approximately 400 PSI test centers across the country. Get complete details on how to find and apply for written exams.
- Find a practical test site and schedule your practical exam(s). Either find an open practical test site or hire a practical examiner. Get complete details on how to find and apply for practical exams.
- Once you have passed your written and practical exams, NCCCO will mail your certification card. Certification status can also be verified using the Verify CCO Online system.
NCCCO certification is valid for five years. Recertification candidates must complete all recertification requirements during the 12 months prior to their certification’s expiration date. In most cases, a practical exam is not required for recertification, only a written exam.
Certifying In House
In addition to arranging training employers can also host written and/or practical NCCCO testing at their site.
Hosting written exams does not have any costs associated with it as long as minimum candidates and form submission timelines are met, although someone will need to be designated as the written test site coordinator. This primarily involves setting up an indoor testing room with an appropriate number of desks or tables, notifying NCCCO and coordinating with the NCCCO chief examiner who will administer the exams. Full instructions for establishing a written test site are on the NCCCO website and contained in the NCCCO Written Test Site Coordinator Handbook. Sites can choose to be either closed to only their employees or open to all candidates seeking to take NCCCO written exams. Written exam test sites may host any and all NCCCO written exams (including recertification exams), not just the dedicated pile driver operator exam.
Similarly, employers with the appropriate equipment available can opt to become a practical exam test site. As with written exams, the site can either be open to anyone eligible to take the exam or closed to the public and only available to employees. These sites are restricted to specific types of equipment, so a dedicated pile driver operator practical exam site is not automatically eligible to offer other NCCCO practical exams unless it has the appropriate equipment and has registered the test site with NCCCO.
A test site application and fee are required to establish a test site, and an NCCCO-accredited practical examiner is required. Find a list of Practical Examiners available for hire on the NCCCO website. Practical test sites also require a practical test site coordinator; this person can be the practical examiner, or another person can be so designated. As described in the Dedicated Pile Driver Test Site Coordinator Handbook, the test site coordinator works with the practical examiner to schedule the exam, prepare the test site according to NCCCO requirements, designate a proctor to help the examiner during testing and coordinate the candidates who will test there.
NCCCO-certified dedicated pile driver operators can also choose to become accredited to administer practical exams by attending a dedicated pile driver operator practical examiner accreditation program (PEAP) workshop, which is an in-person class lasting three days. NCCCO practical examiners are recognized as professionals in their field and may offer their services for hire. Employers with NCCCO-accredited practical examiners on staff appreciate the convenience of being able to schedule in-house tests to accommodate changing schedules caused by weather, workloads and other factors.
NCCCO is actively searching for additional facilities to host dedicated pile driver operator practical exams and PEAP workshops. In recognition of the time, labor and materials the host site contributes to the event, registration for one employee of the company is complimentary. The host also saves travel and hotel expenses by holding exams and workshops at its facility. Moreover, as a result of preparing for the workshop, the site is set up as an official CCO practical exam test site and is ready to begin testing without delay. Finally, having experienced NCCCO instructors there ensures that the test course is set up properly and there is everything needed to conduct CCO practical exams once the PEAP workshop is over.
This article originally appeared in Pile Driver Magazine, February 2021.